On 1st April 2015, by virtue of Italy’s two Ministerial Decrees signed by Pier Carlo Padoan (the Decrees), 21 countries have been removed from the list of countries considered to be tax havens (Black List). In relation to countries included in the Black List costs paid by an Italian business to entities established in such countries are generally not deductible in Italy save for very few exceptions.

It is interesting to note that in relation to the Controlled Foreign Companies included in the Black List - which, pursuant to art. 167 of the Italian Tax Code (known as TUIR), if they receive any income, such income will be allocated to the resident Italian entity in proportion to the relevant holding –countries like Philippines, Malaysia and Singapore have been deleted from the Black List on the basis that they have an agreement on exchange of information with Italy and apply a tax regime which provides for overall tax liabilities not less than half of those applied in Italy.